Complying with the IRS’s Affordable Care Act Reporting ...€¦ · 11/18/2015 1 Complying with the IRS’s Affordable Care Act Reporting Requirements Diane Juffras and Bob Joyce

11/18/2015

1

Complying with the IRS’s

Affordable Care Act Reporting Requirements

Diane Juffras and Bob Joyce

School of Government

UNC-Chapel Hill

Thursday, November 19, 2015

Overview: Two Mandates

Overview: Two Mandates

The Affordable Care Act imposes two kinds of new requirements:

• The Individual Mandate

• The Employer Mandate

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Overview: Individual Mandate

Individuals must

1) secure “minimum essential coverage”

or

2) make a shared responsibility payment with their tax return

Overview: Employer Mandate

Employers of 50* or more full-time equivalent employees must

1) offer coverage that is affordable and provides “minimum value”

to full time employees and dependents

or

2) face penalties

Overview: IRS Wants to Know

Is each individual getting coverage?

Is each covered employer meeting its obligation to offer coverage?

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Overview: IRS and Individuals

So how does IRS learn about individuals?


IRS learns about whether individuals are getting coverage two ways



1) It asks each individual on the Form 1040 when individuals file

their taxes

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their taxes

2) It double checks that through Forms 1094 B and 1095 B




their taxes

2) It double checks that through Forms 1094 B and 1095 B

• 1094 B is the sort of “cover sheet”

• 1095 B is the substantive report


Here are the 1094 B and 1095 B forms:

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1115

Under penalties of perjury, I declare that I have examined this return and accompanying documents, and, to the best of my knowledge and belief, they are true, correct and complete.

▲

Signature

▲

Title

▲

Date

For Privacy Act and Paperwork Reduction Act Notice, see separate instructions. Cat. No. 61570P Form 1094-B (2015)

Form 1094-BDepartment of the Treasury Internal

Revenue Service

Transmittal of Health Coverage InformationReturns

▶ Information about Form 1094-B and its separate instructions is at www.irs.gov/form1094b.

OMB No. 1545-2252

2015

1 Filer's name 2 Employer identification number (EIN) For Official Use Only

3 Name of person to contact 4 Contact telephone number

5 Street address (including room or suite no.) 6 City or town

7 State or province 8 Country and ZIP or foreign postal code

9 Total number of Forms 1095-B submitted with this transmittal . . . . . . . . . . . . . . ▶

560115

For Privacy Act and Paperwork Reduction Act Notice, see separate instructions. Cat. No. 60704B Form 1095-B (2015)

Form 1095-B Department of the Treasury Internal Revenue Service

Health Coverage VOID

CORRECTED▶ Information about Form 1095-B and its separate instructions is at www.irs.gov/form1095b.

OMB No. 1545-2252

2015

Part I Responsible Individual1 Name of responsible individual 2 Social security number (SSN) 3 Date of birth (If SSN is not available)

4 Street address (including apartment no.) 5 City or town 6 State or province 7 Country and ZIP or foreign postal code

8 Enter letter identifying Origin of the Policy (see instructions for codes): . . . . . . ▶ 9 Small Business Health Options Program (SHOP) Marketplace identifier, if applicable

Part II Employer Sponsored Coverage (see instructions)10 Employer name 11 Employer identification number (EIN)

12 Street address (including room or suite no.) 13 City or town 14 State or province 15 Country and ZIP or foreign postal code

Part III Issuer or Other Coverage Provider (see instructions)16 Name 17 Employer identification number (EIN) 18 Contact telephone number


Part IV Covered Individuals (Enter the information for each covered individual(s).)(a) Name of covered individual(s) (b) SSN (c) DOB (If SSN is not

available)

(d) Covered all

12 months

(e) Months of coverage

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

23

24

25

26

27

28


Who files the 1094 B and the 1095 B with the IRS?

http://www.irs.gov/form1094b


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“Every person that provides minimum essential coverage to an individual”



• For employers who offer fully insured plans to their employees,

the insurance company files

• For employers who offer self-funded plans to their employees,

the employer files (even if they would not be required to file

under the employer mandate)

Overview: IRS and Employers

How does the IRS learn whether an employer is meeting its

obligations to offer coverage?

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IRS learns whether an employer is meeting its obligations to offer

coverage to full time employees through Forms 1094 C and 1095 C


Here are the 1094 C and 1095 C forms:

120116

CORRECTEDForm 1094-C

Department of the Treasury

Internal Revenue Service

Transmittal of Employer-Provided Health Insurance Offer andCoverage Information Returns

▶ Information about Form 1094-C and its separate instructions is at www.irs.gov/form1094c

OMB No. 1545-2251

2015Part I Applicable Large Employer Member (ALE Member)1 Name of ALE Member (Employer) 2 Employer identification number (EIN)

3 Street address (including room or suite no.)

4 City or town 5 State or province 6 Country and ZIP or foreign postalcode


For Official Use Only

17 Reserved . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

18 Total number of Forms 1095-C submitted with this transmittal . . . . . . . . . . . . . . . . . . .

19 Is this the authoritative transmittal for this ALE Member? If “Yes,” check the box and continue. If “No,” see instructions

Part II ALE Member Information

20 Total number of Forms 1095-C filed by and/or on behalf of ALE Member . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . .

.

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21 Is ALE Member a member of an Aggregated ALE Group? . . . . . . . . . . . . . . . . . . .

.

. . . . . . . . . .

.Yes No

▲

Signature

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Title

▲

Date

For Privacy Act and Paperwork Reduction Act Notice, see separate instructions. Cat. No. 61571A Form 1094-C (2015)

http://www.irs.gov/form1094c

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600116VOID

CORRECTEDForm 1095-CDepartment of the TreasuryInternal Revenue Service

Employer-Provided Health Insurance Offer and Coverage


OMB No. 1545-2251

2015Part I Employee1 Name of employee 2 Social security number (SSN)

3 Street address (including apartment no.)

4 City or town 5 State or province 6 Countryand ZIP or foreign postal code 11 City or town

Applicable Large Employer Member (Employer)7 Name of employer 8 Employer identification number (EIN)

9 Street address (including room or suite no.) 10 Contact telephone number

12 State or province 13 Country andZIP or foreign postalcode

Part II Employee Offer and Coverage

All 12Months Jan Feb

Plan Start Month (Enter 2-digit number):

June July Aug SeptMar Apr May Oct Nov Dec

14 Offer ofCoverage (enter required code)

15 Employee Shareof Lowest Cost Monthly Premium, for Self-Only Minimum ValueCoverage $ $ $ $ $ $ $ $ $ $ $ $ $

16 Applicable Section 4980H SafeHarbor (enter code,if applicable)

Part III Covered IndividualsIf Employer provided self-insured coverage, check the box and enter the information for each covered individual.

For Privacy Act and Paperwork Reduction Act Notice, see separate instructions. Cat. No. 60705M Form 1095-C (2015)

(a) Name of covered individual(s) (b) SSN (c) DOB (If SSN

is not available)

(d) Covered

all 12 months

(e) Months of Coverage

Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec

17

18

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20

21

22

120216

Page 2Form 1094-C (2015)

Form 1094-C (2015)

Part III IIIIALE Member Information—Monthly

(a) Minimum Essential Covera

Offer Indicator

ge (b) Full-Time Employee Count for

ALE Member

(c) Total Employee Count for

ALE Member

(d) Aggregated

Group Indicator

(e) Section 4980H

Yes No

23 All 12 Months

24 Jan

25 Feb

26 Mar

27 Apr

28 May

29 June

30 July

31 Aug

32 Sept

33 Oct

34 Nov

35 Dec

120216

Page 2Form 1094-C (2015)

Form 1094-C (2015)

Part IV III ALE Member Information—Monthly

(a) Minimum Essential Covera Offer

Indicator

ge (b) Full-Time Employee Count for ALE

Member

(c) Total Employee Count for ALE

Member

(d) Aggregated Group

Indicator

(e) Section 4980H

Yes No

23 All 12 Months

24 Jan

25 Feb

26 Mar

27 Apr

28 May

29 June

30 July

31 Aug

32 Sept

33 Oct

34 Nov

35 Dec


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120315

Page 3Form 1094-C (2015)

Part IV Other ALE Members of Aggregated ALE Group

Enter the names and EINs of Other ALE Members of the Aggregated ALE Group (who were members at any time during the calendar year).

Form 1094-C (2015)

Name EIN Name EIN

36 51

37 52

38 53

39 54

40 55

41 56

42 57

43 58

44 59

45 60

46 61

47 62

48 63

49 64

50 65


Who files the 1094 C and the 1095 C with the IRS?



Every employer of 50 or more full time equivalent employees

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Every employer of 50 or more full time equivalent employees

That’s right. Even if the penalties cannot apply to you for 2015

because you are under 100, you still have to file the 1094 C and

the 1095 C

Overview: Telling Employees


It’s not just the IRS that gets the forms

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Employees get forms, too




Whoever provides the 1094 B and 1095 B to the IRS must

provide the 1095 B to employees as well as the IRS




Whoever provides the 1094 B and 1095 B to the IRS must

provide the 1095 B to employees as well as the IRS

The employer must provide the 1095 C to employees as well as

to the IRS

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Overview: Reporting Options

Overview: Reporting Options

Filing strategy

• All-in house: employer fills in forms and transmits directly to IRS

• Partial outsource: employer fills in forms and uses third-party software to transmit forms to IRS

• Full outsource: third party fills in forms and transmits to IRS

Overview: Size and Reporting

• Under 50 FTE and offer no coverage: no reporting requirement

• Under 50 FTE but offer coverage through an insured plan:

no reporting requirement (but the insurer will report on Form 1094 B)

• Under 50 FTE but offer a self-insured plan: you must file, like a covered larger employer

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Overview: Size and Reporting

• Between 50 and 100: because of “transitional relief,” no possibility of penalty for 2015, but you must report anyway

• Over 100: all reporting requirements apply

• Over 250: special requirement of electronic reporting applies

Overview: Special Rules for 2015


Remember (this is obvious but sometimes confusing) we are

talking about reporting requirements in 2016 for 2015

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Special Rule #1

• For employers with 50-99 FTE employees, there can be no penalty for failure to offer coverage

Special Rules for 2015

Special Rule #1

• For employers with 50-99 FTE employees, there can be no

penalty for failure to offer coverage

• But you still have to file with the IRS and furnish statements to

employees


Special Rule #2

• If you owe a penalty, it will be less that it otherwise would be

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Special Rule #2

• If you owe a penalty, it will be less that it otherwise would be

• That’s because the way of calculating the penalty is special for 2015


Special Rule #2

• If you owe a penalty, it will be less that it otherwise would be.

• That’s because the way of calculating the penalty is special for 2015

• The penalty will based on the number of your actual employees minus 80; it future years it will be minus 30


Special Rule #3

Delay of possibility of penalty for non-calendar year plans

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Special Rule #4

If you file your forms with the IRS for 2015 but you screw them up

because they are so hard, you will not be imposed a filing penalty

if you can show that you “have made good faith efforts to comply

with the information reporting requirements”

Overview Over

Enough with the big picture

Let’s look at the reporting obligations in detail

But first . . . ACA Basics

• “Understanding the Affordable Care Act: What Employers Need to Know,” presented on November 20, 2014

• Retitled by the web designers as “Affordable Care Act Webinar On-Demand”

• Purchase or access: http://www.sog.unc.edu/courses/webinars/affordable-health-care-act-webinar-demand

http://www.sog.unc.edu/courses/webinars/affordable-health-care-act-webinar-demand

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The Forms

Reporting Substantive Information:

• Forms 1095-B and 1095-C

Transmittal Cover Sheets Reporting Summary Information

• Forms 1094-B and 1094-C

Number of FTEs Fully-Insured Plan Self-Insured Plan

100 or moreSubject to reporting & penalties

Form 1095-C, Parts I and II only for each employee who was a F/T employee for at least one month of the calendar yearInsurer will file 1095-B

Form 1095-C, Parts I, II and III for any employee enrolled in coverage

50 – 100Subject to reporting, but not to penalties for 2015

Form 1095-C, Parts I and II only for each employee who was a F/T employee for at least one month of the calendar yearInsurer will file 1095-B

Form 1095-C, Parts I, II and III

Fewer than 50Will never be subject to penalties but offers of coverage must be reported

Employer does not fileInsurer will file 1095-B

Employer files Form 1095-B

120116






OMB No. 1545-2251





9 Name of Designated Government Entity (only if applicable)

LEAVE BLANK10 Employer identificationnumber(EIN)

LEAVE BLANK


LEAVE BLANK

12 City or town

LEAVE BLANK13 State or province

LEAVE BLANK14 Country andZIP or foreign postal code

LEAVE BLANK

15 Name of person to contact

LEAVE BLANK16 Contact telephone number

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.Yes No

If “No,” do not complete Part IV.

22 Certifications of Eligibility (select all that apply):

A. Qualifying Offer Method B. Qualifying Offer Method Transition Relief C. Section 4980H Transition Relief D. 98% Offer Method

Under penalties of perjury, I declare that I have examined this return and accompanying documents, and to the best of my knowledge and belief, they are true, correct, and complete.

▲

Signature

▲

Title

▲

Date


Fill out lines 20 – 22 only on the

Authoritative Transmittal XLocal Gov’t Employers Answer No


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Qualifying Offer:

An offer of minimum essential coverage that provides minimum

value and is affordable, made to a full-time employee for whom a

no-coverage or inadequate coverage penalty could apply. The

offer must include an offer of minimum essential coverage (MEC)

to the employee’s spouse and dependents.

Qualifying Offer:

An offer of minimum essential coverage that provides minimum value and is

affordable, made to a full-time employee for whom a no-coverage or inadequate

coverage penalty could apply. The offer must include an offer of minimum essential

coverage (MEC) to the employee’s spouse and dependents.

Employer must certify that it made a Qualifying Offer to one or more F/T employees

for all the month that the employee was a F/T employee for whom a no-coverage or

inadequate coverage penalty could apply.

Qualifying Offer Method of Reporting

120116






OMB No. 1545-2251







LEAVE BLANK


LEAVE BLANK

12 City or town



LEAVE BLANK



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X


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600116VOID




OMB No. 1545-2251

















is not available)

(d) Covered

all 12 months



17

18

19

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22

Line 14

Line 15

Line 16

1A

Employer InfoEmployee Info

1A 1A 1A 1A 1A 1A 1A 1A 1A1I 1I 1IIndicator Codes for Line 14 are on page __ of your materials

120116






OMB No. 1545-2251







LEAVE BLANK


LEAVE BLANK

12 City or town



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17 Reserved . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .





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Yes No





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X

Qualifying Offer Method Transition Relief for 2015

Employer must certify that it made a Qualifying Offer for one or

more months of the calendar year to at least 95% of its full-time

employees (not including employees in a LNP).



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120116






OMB No. 1545-2251







LEAVE BLANK


LEAVE BLANK

12 City or town



LEAVE BLANK



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X X

600116VOID




OMB No. 1545-2251

















is not available)

(d) Covered

all 12 months



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Line 14

Line 15

Line 16

1A

Employer InfoEmployee Info

1A 1A 1A 1A 1A 1A 1A 1A 1A1I 1I 1IIndicator Codes for Line 14 are on page __ of your materialsNever enter

anything in

Line 15 when

you are using

Codes 1A or 1I

and you are

using the

Qualifying

Offer

Transition

Relief

120116






OMB No. 1545-2251







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Section 4980H Transitional Relief

1. Employers with 50 – 99 employees (including FTEs)

2. Employers with 100 or more employees (including FTEs)

120116






OMB No. 1545-2251







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X XX

98% Offer Method

An employer who offers affordable, minimum value health

insurance coverage to 98% of all of its employees (and their

dependents for whom it is filing a Form 1095-C is not required to

report the number of its full-time employees for 2015 in Part III of

Form 1094-C (the transmittal form).


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120216

Page 2Form 1094-C (2015)

Form 1094-C (2015)

Part IIIN IIIIALE Member Information—Monthly


Offer Indicator


ALE Member


ALE Member

(d) Aggregated

Group Indicator

(e) Section 4980H

Yes No

23 All 12 Months

24 Jan

25 Feb

26 Mar

27 Apr

28 May

29 June

30 July

31 Aug

32 Sept

33 Oct

34 Nov

35 Dec

Do not count employees in a limited non-assessment period

in responding to columns (a) and (b)

Include F/T, P/T

and employees in

LNP

N/AUse indicator code A if

claiming 2015 transition

relief for employers with

50-99 FTEs.

Use indicator code B if

claiming 2015 transition

relief for employers with

100 or more FTEs.

Employers certifying

eligibility for 98% Offer

reporting do not have to

fill out column (b)

Coverage to

95% of F/T

employees and

dependents ?

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

120216

Page 2Form 1094-C (2015)

Form 1094-C (2015)

Part IIIN IIIIALE Member Information—Monthly


Offer Indicator


ALE Member


ALE Member

(d) Aggregated

Group Indicator

(e) Section 4980H

Yes No

23 All 12 Months X 269 B

24 Jan 344

25 Feb 344

26 Mar 341

27 Apr 342

28 May 342

29 June 375

30 July 377

31 Aug 373

32 Sept 343

33 Oct 343

34 Nov 343

35 Dec 343



Include F/T, P/T and employees

in LNPN/A

Use indicator codes A or B if claiming 2015

transition relief from ACA employer penalties.

120216

Page 2Form 1094-C (2015)

Form 1094-C (2015)

Part III IIIIALE Member Information—Monthly


Offer Indicator


ALE Member


ALE Member

(d) Aggregated

Group Indicator

(e) Section 4980H

Yes No

23 All 12 Months

24 Jan 66

25 Feb

26 Mar

27 Apr

28 May

29 June

30 July

31 Aug

32 Sept

33 Oct

34 Nov

35 Dec



Include F/T, P/T and employees

in LNPN/A

Use indicator codes A or B if claiming 2015

transition relief from ACA employer penalties.

x

x

x

x

x

x

x

x

x

x

x

xx

66

66

68

68

68 (80)

68 (82)

68 (80)

67

67

66

68

75

73

75

77

77

93

95

93

76

76

75

79

A

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120315

Page 3Form 1094-C (2015)

Part IV Other ALE Members of Aggregated ALE Group

Enter the names and EINs of Other ALE Members of the Aggregated ALE Group (who were members at any time during the calendar year).

Form 1094-C (2015)

Name EIN Name EIN

36 51

37 52

38 53

39 54

40 55

41 56

42 57

43 58

44 59

45 60

46 61

47 62

48 63

49 64

50 65

Questions on Form 1094-C?

600116VOID




OMB No. 1545-2251

















is not available)

(d) Covered

all 12 months



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Optional 2015; Mandatory 2016

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Indicator Code Series 1 (see p. __ of materials for full list)

1A. Qualifying Offer: Minimum essential coverage providing minimum value offered to full-time

employee with employee contribution for self-only coverage equal to or less than 9.5% mainland

single federal poverty line (in other words, AFFORDABLE) and at least minimum essential

coverage offered to spouse and dependent(s).

1F. Minimum essential coverage NOT providing minimum value offered to employee; employee

and spouse or dependent(s); or employee, spouse and dependents.

1G. Offer of coverage to employee who was not a full-time employee for any month of the

calendar year (which may include one or more months in which the individual was not an

employee) and who enrolled in self-insured coverage for one or more months of the calendar

year.

1H. No offer of coverage (employee not offered any health coverage or employee offered

coverage that is not minimum essential coverage, which may include one or more months in

which the individual was not an employee).

1I. Qualifying Offer Transition Relief 2015: Employee (and spouse or dependents) received no

offer of coverage; received an offer that is not a qualifying offer; or received a qualifying offer for

less than 12 months.

600116VOID




OMB No. 1545-2251

















is not available)

(d) Covered

all 12 months



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01

Line 14

Line 15

Line 16

Jennifer Johnson 555-55-5555

723 Tar Heel Dr.

Paradise N.C. 12345

City of Paradise, N.C. 00-0000000

987 Awesome St.

Paradise N.C. 12345

919-999-9999

1A

600116VOID




OMB No. 1545-2251

















is not available)

(d) Covered

all 12 months



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Charles Lee 333-33-3333

678 Logoff Lane

Tinsel City N.C. 12345

City of Paradise 00-0000000

987 Awesome St.

Paradise N.C. 12345

919-999-9999

1H 1H 1H 1H 1H 1H 1A 1A 1A 1A 1A 1A Code 1H = No Offer of Coverage



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600116VOID




OMB No. 1545-2251

















is not available)

(d) Covered

all 12 months



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James Smith 222-22-2222

541 Fairview Drive

Paradise N.C. 12345


987 Awesome St.

Paradise N.C. 12345

919-999-9999

1H 1H 1H 1H 1H 1H 1A 1A 1A 1A 1A 1A

600116VOID




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is not available)

(d) Covered

all 12 months



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Line 14

Line 15

Line 16


723 Tar Heel Dr.

Paradise N.C. 12345


987 Awesome St.

Paradise N.C. 12345

919-999-9999

1A

Fill in line 15

only if you

have entered

1B, 1C, 1D or

1E on line 14

1B. Minimum essential coverage providing minimum value offered to employee only. [not affordable]

1C.Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to dependent(s) (not spouse). [not affordable]

1D.Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to spouse (not dependent(s)). [not affordable]

1E. Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to dependent(s) and spouse. [not affordable]



11/18/2015

26

600116VOID




OMB No. 1545-2251

















is not available)

(d) Covered

all 12 months



17

18

19

20

21

22

01

Line 14

Line 15

Line 16


723 Tar Heel Dr.

Paradise N.C. 12345

City of Paradise, North Carolina 00-0000000

987 Awesome St.

Paradise N.C. 12345

919-999-9999

1A

Only self-insured

employers fill in Part III.

Insurers provide Part III

information for employers

with fully-insured plans.

2C

X

William Johnson 888-88-8888 X X X X XX X

Susan Johnson

William Johnson, Jr.

333-33-3333

10/31/15 X X

X

Safe Harbor Indicators – Code Series 2

2C Use for any month in which an employee is enrolled in MEC (your health plan)

2A Employee was not your employee on any day of that month

2B Employee was not F/T and did not enroll in coverage, if offered

Use also for F/T employee whose coverage ended during that month

b/c employment during that month

Use for Jan. 2015 if employee was offered MV, affordable coverage by

the first day of the first payroll period of January.

Safe Harbor Indicators – Code Series 2 cont.

2D Employee was in limited non-assessment period

2F Use if the Form W-2 Safe Harbor used

2G Use if the Federal Poverty Line Safe Harbor used

2H Use if Rate of Pay Safe Harbor used

2I Noncalendar year transition relief


11/18/2015

27

600215

Page 2Form 1095-C (2015)

Instructions for RecipientYou are receiving this Form 1095-C because your employer is an Applicable Large Employer subject to the employer shared responsibility provision in the Affordable Care Act. This Form 1095-C includes information about the health insurance coverage offered to you by your employer. Form 1095-C, Part II, includes information about the coverage, if any, your employer offered to you and your spouse and dependent(s). If you purchased health insurance coverage through the Health Insurance Marketplace and wish to claim the premium tax credit, thisinformation will assist you in determining whether you are eligible. For more information about the premium tax credit, see Pub. 974, Premium Tax Credit (PTC). You may receive multiple Forms 1095-C if you had multiple employers during the year that were Applicable Large Employers (for example, you left employment with one Applicable Large Employer and began a new position of employment with another Applicable Large Employer). In that situation, each Form 1095-C would have information only about the health insurance coverage offered to you by the employer identified on the form. If your employer is not an Applicable Large Employer it is not required tofurnish you a Form 1095-C providing information about the health coverage it offered.

In addition, if you, or any other individual who is offered health coverage because of their relationship to you (referred to here as family members), enrolled in your employer's health plan and that plan is a type of plan referred to as a "self-insured" plan, Form 1095-C, Part III provides information to assist you in completing your income tax return by showing you or those family members had qualifying health coverage (referred to as "minimum essential coverage") for some or all months during the year.

If your employer provided you or a family member health coverage through an insured health plan or in another manner, the issuer of the insurance or the sponsor of the plan providing the coverage will furnish you information about the coverage separately on Form 1095-B, Health Coverage. Similarly, if you or a family member obtained minimum essential coverage fromanother source, such as a government-sponsored program, an individual market plan, ormiscellaneous coverage designated by the Department of Health and Human Services, the provider of that coverage will furnish you information about that coverage on Form 1095-B. If you or a family member enrolled in a qualified health plan through a Health Insurance Marketplace, the Health Insurance Marketplace will report information about that coverage on Form 1095-A, Health Insurance Marketplace Statement.

Employers are required to furnish Form 1095-C only to the employee. As the recipient of this Form 1095-C, you should provide a copy to any family membersTIPcovered under a self-insured employer-sponsored plan listed in Part III if they request it for their records.

Part I. Employee

Lines 1–6. Part I, lines 1–6, reports information about you, the employee.

Line 2. This is your social security number (SSN). For your protection, this form may show onlythe last four digits of your SSN. However, the issuer is required to report your complete SSN tothe IRS.

▲!CAUTION

If you do not provide your SSN and the SSNs of all covered individuals to the plan administrator, the IRS may not be able to match the Form 1095-C to determine thatyou and the other covered individuals have complied with the individual sharedresponsibility provision. For covered individuals other than the employee listed in

Part I, a Taxpayer Identification Number (TIN) may be provided instead of an SSN.

Part I. Applicable Large Employer Member (Employer)

Lines 7–13. Part I, lines 7–13, reports information about your employer.

Line 10. This line includes a telephone number for the person whom you may call if you havequestions about the information reported on the form or to report errors in the information on the form and ask that they be corrected.

Part II. Employer Offer and Coverage, Lines 14–16Line 14. The codes listed below for line 14 describe the coverage that your employer offered toyou and your spouse and dependent(s), if any. (If you received an offer of coverage through amultiemployer plan due to your membership in a union, that offer may not be shown on line 14.)The information on line 14 relates to eligibility for coverage subsidized by the premium tax credit for you, your spouse, and dependent(s). For more information about the premium tax credit, seePub. 974.

1A. Minimum essential coverage providing minimum value offered to you with an employee contribution for self-only coverage equal to or less than 9.5% of the 48 contiguous states single federal poverty line and minimum essential coverage offered to your spouse and dependent(s) (referred to here as a Qualifying Offer). This code may be used to report for specific months for which a Qualifying Offer was made, even if you did not receive a Qualifying Offer for all 12 months of the calendar year.

1B. Minimum essential coverage providing minimum value offered to you and minimum essential coverage NOT offered to your spouse or dependent(s).

1C. Minimum essential coverage providing minimum value offered to you and minimum essential coverage offered to your dependent(s) but NOT your spouse.

1D. Minimum essential coverage providing minimum value offered to you and minimum essential coverage offered to your spouse but NOT your dependent(s).

1E. Minimum essential coverage providing minimum value offered to you and minimum essential coverage offered to your dependent(s) and spouse.

1F. Minimum essential coverage NOT providing minimum value offered to you, or you and your spouse or dependent(s), or you, your spouse, and dependent(s).

1G. You were NOT a full-time employee for any month of the calendar year but were enrolled in self-insured employer-sponsored coverage for one or more months of the calendar year. Thiscode will be entered in the All 12 Months box on line 14.

1H. No offer of coverage (you were NOT offered any health coverage or you were offered coverage that is NOT minimum essential coverage).

1I. Your employer claimed "Qualifying Offer Transition Relief" for 2015 and for at least one month of the year you (and your spouse or dependent(s)) did not receive a Qualifying Offer. Note that your employer has also provided a contact number at which you may request further information about the health coverage, if any, you were offered (see line 10).

Line 15. This line reports the employee share of the lowest-cost monthly premium for self-only minimum essential coverage providing minimum value that your employer offered you. Theamount reported on line 15 may not be the amount you paid for coverage if, for example, you chose to enroll in more expensive coverage such as family coverage. Line 15 will show an amount only if code 1B, 1C, 1D, or 1E is entered on line 14. If you were offered coverage but not required to contribute any amount towards the premium, this line will report a “0.00” for the amount.

Line 16. This code provides the IRS information to administer the employer shared responsibility provisions. Other than a code 2C which reflects your enrollment in your employer's coverage, none of this information affects your eligibility for the premium tax credit. For more information about the employer shared responsibility provisions, see IRS.gov.

Part III. Covered Individuals, Lines 17–22Part III reports the name, SSN (or TIN for covered individuals other than the employee listed in Part I), and coverage information about each individual (including any full-time employee and non-full-time employee, and any employee's family members) covered under the employer'shealth plan, if the plan is "self-insured." A date of birth will be entered in column (c) only if an SSN (or TIN for covered individuals other than the employee listed in Part I) is not entered in column (b). Column (d) will be checked if the individual was covered for at least one day in every month of the year. For individuals who were covered for some but not all months, information will be entered in column (e) indicating the months for which these individuals were covered. If there are more than 6 covered individuals, see the additional covered individuals on Part III, Continuation Sheet(s).

Form 1095-C (2015)

600316

Page 3

Form 1095-C (2015)

Name of employee Social security number (SSN)

Part III Covered Individuals — Continuation Sheet(a) Name of covered individual(s) (b) SSN (c) DOB (If SSN is

not available)

(d)

Covered all

12 months


Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec

23

24

25

26

27

28

29

30

31

32

33

34


Where a new part-time, seasonal or variable hour

employee is either not an employee or is in his or her initial

measurement period (i.e., in a limited non-assessment period)

for each month during the calendar year, then no Form 1095-

C need be filed for the new hire for the year.

11/18/2015

28

Self-Insured Health Plans

• Issuers of health insurance must report information on persons covered by

employer-sponsored insurance on Form 1094-B (transmittal sheet) and Form

1095-B (issued to each employee)

• Covered employers (ALEs) with self-insured plans may use Part III of Form 1095-

C to satisfy this requirement.

This includes members of the NCLM Municipal Insurance Trust

• Small employers who are not covered by the ACA employer mandate but who

offer health coverage through a self-insured plan must fill out Form 1094-B and

1095-B.

This includes members of the NCLM Municipal Insurance Trust

Questions on Form 1095-C?

1115

Under penalties of perjury, I declare that I have examined this return and accompanying documents, and, to the best of my knowledge and belief, they are true, correct and complete.

▲

Signature

▲

Title

▲

Date

For Privacy Act and Paperwork Reduction Act Notice, see separate instructions. Cat. No. 61570P Form 1094-B (2015)

Form 1094-BDepartment of the Treasury


Transmittal of Health Coverage InformationReturns


OMB No. 1545-2252

2015

1 Filer's name 2 Employer identification number (EIN) For Official Use Only


5 Street address (including room or suite no.) 6 City or town

7 State or province 8 Country and ZIP or foreign postal code

9 Total number of Forms 1095-B submitted with this transmittal . . . . . . . . . . . . .

.

▶

This form and its companion, Form 1094-C, are required only of employers sponsoring self-insured health plans

Paradise County, North Carolina 11-0000000

Margaret Smith (919) 555-6666

246 Main Street Paradise

North Carolina 12346

33


11/18/2015

29

Form 1095-B (2015)

Form 1095-BDepartment of the Treasury Internal Revenue Service

Health CoverageOMB No. 1545-2252

2015

Part I Responsible Individual

1 Name of responsible individual 2 Social security number (SSN) 3 Date of birth (If SSN is not available)

4 Street address (including apartment no.) 5 City or town 6 State or province 7 Country and ZIP or foreign postal code

8 Enter letter identifying Origin of the Policy (see instructions for codes): . . . . . . ▶ 9 Small Business Health Options Program (SHOP) Marketplace identifier, if applicable

Part II Employer Sponsored Coverage (see instructions)

10 Employer name 11 Employer identification number (EIN)


Part III Issuer or Other Coverage Provider (see instructions)

16 Name 17 Employer identification number (EIN) 18 Contact telephone number


Part IV Covered Individuals (Enter the information for each covered individual(s).)

(a) Name of covered individual(s) (b) SSN (c) DOB (If SSN is not

available)

(d) Covered

all 12 months



23

24

25

26

27

28


Sally Mployee

891 Valley Street Paradise Heights

666-66-6666

North Carolina 12347

B

THIS MEANS

THE

EMPLOYEE

NO EMPLOYER SHOULD FILL OUT PART II

Self-insured

small employers

fill out Parts III

and IV

Paradise County, North Carolina 11-0000000 (919) 555-6666

246 Main Street Paradise NC 12346

Sally Mployee 666-66-6666X

Mark “X” if

employee was

covered for at

least one day for

all 12 months

Roy Spousie 888-88-8888 X X X X XX

560215

Page 2Form 1095-B (2015)

Instructions for RecipientThis Form 1095-B provides information needed to report on your income tax return that you, your spouse (if you file a joint return), and individuals you

claim as dependents had qualifying health coverage (referred to as “minimumessential coverage”) for some or all months during the year. Individuals who

don't have minimum essential coverage and don't qualify for an exemption

from this requirement may be liable for the individual shared responsibility payment.

Minimum essential coverage includes government-sponsored programs,eligible employer-sponsored plans, individual market plans, and other

coverage the Department of Health and Human Services designates asminimum essential coverage. For more information on the requirement to

have minimum essential coverage and what is minimum essential coverage, see www.irs.gov/Affordable-Care-Act/Individuals-and-Families/Individual-

Shared-Responsibility-Provision.

Providers of minimum essential coverage are required to furnishTIP only one Form 1095-B for all individuals whose coverage is

reported on that form. As the recipient of this Form 1095-B, you

should provide a copy to other individuals covered under the policy if they

request it for their records.

Part I. Responsible Individual, lines 1–9. Part I reports information aboutyou and the coverage.

Lines 2 and 3. Line 2 reports your social security number (SSN) or other taxpayer identification number (TIN), if applicable. For your protection, this

form may show only the last four digits. However, the coverage provider is

required to report your complete SSN or other TIN, if applicable to the IRS.Your date of birth will be entered on line 3 only if line 2 is blank.

▲!CAUTION

If you don't provide your SSN or other TIN and the SSNs or other TINs

of all covered individuals to the sponsor of the coverage, the IRS may

not be able to match the Form 1095-B with the individuals to

determine that they have complied with the individual shared responsibility

provision.

Line 8. This is the code for the type of coverage in which you or other covered individuals were enrolled. Only one letter will be entered on this line.

A. Small Business Health Options Program (SHOP)B. Employer-sponsored coverageC. Government-sponsored programD. Individual market insuranceE. Multiemployer plan

F. Other designated minimum essential coverage

If you or another family member received health insurance

TIP coverage through a Health Insurance Marketplace (also known as

an Exchange), that coverage will be reported on a Form 1095-A

rather than a Form 1095-B.

Line 9. This line will be blank for 2015.

Part II. Employer-Sponsored Coverage, lines 10–15. This part will becompleted by the insurance company if an insurance company provides your

employer-sponsored health coverage. It provides information about the

employer sponsoring the coverage. This part may show only the last four digits of the employer's EIN. If your coverage isn't insured employer

coverage, this part will be blank.

Part III. Issuer or Other Coverage Provider, lines 16–22. This part reports

information about the coverage provider (insurance company, employer providing self-insured coverage, government agency sponsoring coverage

under a government program such as Medicaid or Medicare, or other coverage sponsor). Line 18 reports a telephone number for the coverage

provider that you can call if you have questions about the information

reported on the form.

Part IV. Covered Individuals, lines 23–28. This part reports the name, SSN

or other TIN, and coverage information for each covered individual. A date ofbirth will be entered in column (c) only if SSN or other TIN isn't entered in

column (b). Column (d) will be checked if the individual was covered for at least one day in every month of the year. For individuals who were covered

for some but not all months, information will be entered in column (e)

indicating the months for which these individuals were covered. If there aremore than six covered individuals, see Part IV, Continuation Sheet(s), for

information about the additional covered individuals.

560316

Page 3Form 1095-B (2015)

Form 1095-B (2015)

Name of responsible individual Social security number (SSN) Date of birth (If SSN is not available)

Part IV Covered Individuals — Continuation Sheet(a) Name of covered individual(s) (b) SSN (c) DOB (If SSN is

not available)

(d)

Covered

all 12

months



29

30

31

32

33

34

35

36

37

38

39

40


http://www.irs.gov/Affordable-Care-Act/Individuals-and-Families/Individual-

11/18/2015

30

Questions on Forms 1094-B and 1095-B?

Noncalendar Year Plans

Special Topics

11/18/2015

31

COBRA

How to report an with a COBRA offer?

Depends on how the employee became COBRA eligible.

• Employment ended

• Hours reduced

COBRA—Employment Ended

Employment ends, COBRA is offered.

• Whether the employee takes the COBRA coverage or not, the code on Line 14 is 1H and on Line 16 is 2C.

• Translation: “No coverage offered” (even though COBRA coverage was) and “employee not a full time employee.”

COBRA—Hours Reduced

Hours are reduced, COBRA is offered.

• Whether the employee takes the COBRA coverage or not, the code on Line 14 is 1E and Line 16 depends on whether the employee accepts coverage.

• Translation: “Coverage offered” and the appropriate employee status.

11/18/2015

32

Health Reimbursement Arrangements (HRAs)

• Providers of minimum essential coverage (MEC) must file

Forms 1094-B and 1095-B so that the IRS can enforce the

individual mandate.

• HRAs are considered MEC.

• Integrated HRAs do not have to be separately reported.

Health Reimbursement Arrangements (HRAs): Reporting Rule #1

• If an individual is covered by more than one plan providing MEC

and both plans are offered by the same provider, the provider need

only file information on one of the types of coverage.

• Self-insured employers offering an HRA do not have to report the

HRA. They will simply report the group health plan coverage on

Form 1094-C and 1095-C if a covered employer (ALE) and on

Form 1094-B and 1095-B if a small employer.

Health Reimbursement Arrangements (HRAs): Reporting Rule #1 cont.

• Reporting is done month by month and individual by individual.

• If an individual employee enrolled in both an employer’s self-

insured group health plan and the employer’s HRA ceases to

be covered by the group health plan, the employer must then

report the HRA.

11/18/2015

33

Health Reimbursement Arrangements (HRAs): Reporting Rule #2

• When an individual ‘s eligibility to participate in a HRA depends

on his or her enrollment in the employer’s group health plan, no

additional reporting of the HRA is required.

This rule exempts full-insured employers from having to

report HRA coverage.

Health Reimbursement Arrangements (HRAs): Reporting Rule #2 cont.

• Employers will have to report HRA coverage of employees

who are enrolled in a health plan that is not sponsored by the

same employer – an employee enrolled in a spouse’s health

plan, for example. The HRA must reported by the employer on

Forms 1094-B and 1095-B.

• Reporting is done month by month and individual by individual.

Health Savings Accounts (HSAs)

• HSAs usually offered in conjunction with HDHP

• HSAs are not considered MEC

• Purpose of Form 1094-B and 1095-B reporting is to report MEC for the purposes of showing individual mandate compliance

• Therefore . . . HSAs do not have to be reported

11/18/2015

34

Reporting about Retirees

A covered employer must report, on the 1095 forms, about

coverage offers to current, full-time employees.

But what about coverage offered to retirees?

When must that be reported?


Basic rule:

• If the retiree coverage offered is supplemental to Medicare

(that is, the retiree is 65+), then the coverage need not be reported.


Basic rule:

• If the retiree coverage offered is supplemental to Medicare (that is,

the retiree is 65+), then the coverage need not be reported.

• The retiree is getting “minimum essential coverage” through

Medicare, which will report it, so no need for the employer to report

for the individual mandate, and not an employee for the employer

mandate.

11/18/2015

35


• But what about a retiree under 65 who is on an employer’s

plan? That is, the coverage is not supplemental to Medicare,

but is the main coverage?


• If the employer is self-insured, the employer must report on the

B forms as the provider of minimum essential coverage.

• If the employer’s plan is fully insured, the insurance provider will

report the coverage on the B forms and the employer reports

the coverage on the C forms, using the code for a “non-

employee.”

Questions about COBRA Offers of Coverage?

Questions about HRAs?

Questions about Retirees?

Questions about Non-Calendar Year Plans?

11/18/2015

36

Some Important Facts about Filing: Employee Statements

• Form 1095-C must be sent to employees by January 31st of the

following year.

• Forms may be sent to employees electronically if they consent.

Otherwise, they should be sent by mail or hand-delivered.

• The first report will have to be sent to employees by

February 1, 2016 for the year 2015.

Some Important Facts about Filing: IRS Returns

• Forms must be filed with the IRS on or before February 28 of the following year

(March 31 if filed electronically). Remember, Form 1095-C must be given to both

each employee participating in the employer’s group health plan and the IRS.

• Form 1094-C is the transmittal summary form that goes to the IRS along with the

copies of each Form 1095-C.

• Employers who must file 250 or more of a form will be required to file electronically.

• Extensions of the time in which to file may be requested for Forms 1094 and 1095 as

for any other return.

Penalties for Failure to File

• $250 per day for each Form 1094 and 1095 statement that is

missing, late or incomplete.

• Total annual maximum penalty limit is $3 million.

• Same penalties as for failure to file or late filing of income tax

informational returns to the IRS and the issuance of Forms W-2

and 1099 to employees and independent contractors.

11/18/2015

37

Questions about Filing?

Documents

Complying with the IRS’s Affordable Care Act Reporting ...€¦ · 11/18/2015 1 Complying with the IRS’s Affordable Care Act Reporting Requirements Diane Juffras and Bob Joyce